I am grateful to the Culture, Media and Sport Select
Committee for carrying out its follow-up inquiry into football
governance, and its report, published on 29 January 2013.

I share the Select Committee's frustration at the
football authorities' slow progress in implementing long promised,
and much needed, reforms to the game. I also share your analysis
that there are three key areas where we need to see real progress
made. In particular, the licensing system for clubs, the introduction
of a representative and balanced Board, and improved supporter
engagement at club level. I agree with your recommendation, that
in the absence of significant progress with these by the beginning
of next season, we should seek to introduce legislation as soon
as practically possible.

I have already been given drafting authority by the
Parliamentary Counsel, and my officials have started working up
a draft Bill and supporting documentation, should football fail
to deliver. This Bill will reflect the conclusions of your report.

While most of the Committee's recommendations are
directed towards the football authorities, I thought it might
be useful to re-iterate the Government position on some of the
Committee's key conclusions and recommendations.

REFORM OF THE GOVERNANCE STRUCTURE

I agree with the Committee, that the FA should provide
strategic leadership for all levels of the game, representing
the interests of the professional and national game equally. I
welcome the football authorities' proposal, therefore, to require
all committees to report to the main FA Board. The FA Board should
act on the recommendations of its advisory game boards, but not
be subject to them.

I agree, also, with the Committee that the FA decision-making
bodies should be representative of the modern game and its diverse
stakeholders, and should be equipped with the right balance of
skills, experience and independent expertise to be able to meet
the challenges that arise in the game. While I have previously
made clear that I think a representative and balanced Board is
the first priority, I still expect the FA to deliver its undertaking
to have a Board of between 8-12 members, by the start of the 2013-14
season.

CLUB OWNERSHIP AND SUPPORTERS

My Department continues to urge the football authorities
to make full transparency of club ownership, a key condition of
the new licensing system for clubs. The licensing system should
set out stricter criteria, in terms of owners being both fit and
proper, and around the requirement to have clearly defined business
plans for how they will safeguard the club's future. Taken together,
these would provide greater transparency to clubs' supporters.
In this context, work is also underway across Government to strengthen
the requirements on all companies around ultimate beneficial ownership
disclosure.

I also agree that more needs to be done to ensure
that supporters' interests are given due consideration in any
decision making. I agree with the Committee, that more detail
is needed on how clubs will engage with their supporter groups,
and expect this to be laid out clearly, in the new licensing system.
At the same time, I believe the football authorities should continue
to consider ways to actively encourage and incentivise the inclusion
of supporter representatives on the boards of clubs. I support
the recommendation of the Committee that a long term funding solution
for Supporters Direct is needed. The organisation continues to
provide a valuable service to supporter groups, particularly those
that seek to rescue clubs that have fallen into financial difficulty.

I will be meeting with representatives of Supporter
Direct shortly, with a view to working with them to set up the
working group as recommended by the Committee.

FINANCIAL MATTERS

I agree with the Committee that the new club licensing
system, and the financial rules that underpin this, will be key
to ensuring the long term sustainability of clubs. However, further
detail is required from the football authorities on the content
of the licence, and the role that the new FA Regulatory Authority
(FARA) will have in monitoring and enforcing FA Rules and Regulations.

I join with the Committee in welcoming the recent
progress made by the football authorities and all 92 professional
clubs, in agreeing to adopt Financial Fair Play (FFP) principles.
The implementation of FFP should gradually lead to clubs reducing
their spending, and as a result, see fewer incidents of club insolvencies.
I hope that the FFP, should, in turn, negate the need for football
to rely on the Football Creditors Rule in cases of club insolvencies.
However, we will monitor the effect this self-regulation has on
the financial discipline and solvency of clubs, and, if necessary,
will re-consider whether legislation is needed to address this
issue.

My Department will continue its dialogue with the
football authorities in the coming months, to ensure that necessary
action is taken to deliver these important governance reforms.

A copy of this letter has been sent to David Bernstein,
Chair of the FA.